Takeaways from sanctions enforcement in 2020 and trends in 2021

Jodi Avergun, James Treanor and Shruti Chandhok
Additional contact information
Jodi Avergun: Partner, Cadwalader, Wickersham & Taft, USA
James Treanor: Special Counsel, Cadwalader, Wickersham & Taft, USA
Shruti Chandhok: Associate, Cadwalader, Wickersham & Taft, UK

Journal of Financial Compliance, 2021, vol. 5, issue 2, 123-133

Abstract: The COVID-19 pandemic years of 2020 and 2021 have by no means been record setting for sanctions enforcement, yet reliance on economic sanctions as a tool of foreign policy remains high for policymakers and regulators on both sides of the Atlantic. In the United States, recent enforcement has seen a reprieve from the very large penalties paid by large financial institutions in prior years. In the United Kingdom, regulators brought only one sanctions-related enforcement action (which targeted the dealings of one of the country’s largest banks) in 2020. Thus far, penalties in 2021, both in number and amount, are similar to those of 2020. Through an examination of these enforcement actions as well as formal regulatory guidance, legal, compliance and risk departments can draw a number of lessons to improve the effectiveness of their organisations’ sanctions compliance efforts. Just as importantly, anticipating the sanctions landscape for the second half of 2021 and beyond can help to avoid surprises and maintain a robust risk-based sanctions compliance programme.

Keywords: Sanctions; OFAC; OFSI; Biden administration; Brexit (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2021
References: Add references at CitEc
Citations:

Downloads: (external link)
https://hstalks.com/article/6745/download/ (application/pdf)
https://hstalks.com/article/6745/ (text/html)
Requires a paid subscription for full access.

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:aza:jfc000:y:2021:v:5:i:2:p:123-133

Access Statistics for this article

More articles in Journal of Financial Compliance from Henry Stewart Publications
Bibliographic data for series maintained by Henry Stewart Talks ().